Reports will be evaluated to determine if the subject matter of the report would constitute a potential violation of this Policy. If so, a thorough investigation will be conducted, and appropriate action will be taken. If it is determined that the subject matter of the report would not, even if verified, constitute a violation of this Policy, the reporter will be redirected to the most appropriate mechanism for resolution. All reports will be treated as confidential to the extent practicable. All employees are expected to cooperate in investigations and refrain from interfering with or obstructing an investigation, misrepresenting or withholding information, attempting to discover the identity of anyone cooperating in an investigation, or breaching the confidentiality of an investigation. Doing so will result in appropriate disciplinary action up to and including termination of employment.

Internal audit will regularly report investigation results of reported Concerns to the Audit and Risk Committee of the Board of Trustees for its review.